Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit earnm.com (the "Site").

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, your geo-location and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as "Device Information."

We collect Device Information using the following technologies:

• "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit allaboutcookies.org.
• "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• "Web beacons," "tags," and "pixels" are electronic files used to record information about how you browse the Site.
• We may also use GPS or similar geo-location technology to determine the geo-coordinates of where you or your device is/are located.

When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting this website.

If you wish to opt-out of email marketing from a specific brand that we work with, such as a customer of ours, you can click on the "opt-out" or "unsubscribe" link in the footer of any marketing email you receive.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our users browse and interact with the Site).

Additionally when you register through the Site (e.g., to receive further information or register or apply to a whitelist), we collect certain information from you, including your name and email address. We refer to this information as "Registration Information."

When we talk about "Personal Information" in this Privacy Policy, we are talking both about Device Information and Registration Information.

We use this Registration Information to:

• Communicate with you.
• Keep you up to date about what is going on with the EARN'M Loyalty Ecosystem.
• Legal. We may use your Personal Information to enforce our Terms of Service, to defend our legal rights, to comply with our legal obligations and internal policies.
• Business Partners. We may use your personal information to manage our business relationships, including:
  • with whom we jointly offer products and services;
  • with whom we have entered into an agreement that provides for the disclosure, sale, lease, or license of your Information; or
  • to facilitate a direct relationship with you, including in connection with any program we administer on behalf of the Business Partner.

We use the Device Information that we collect to help us improve and optimize our Site and to assess the success of our marketing campaigns.

We use Google Analytics to help us understand how our customers use the Site — you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.

We may transfer or assign this Privacy Policy and any Personal Information to a third party entity in connection with a merger, acquisition, consolidation, restructuring, the sale of substantially all of our shares and/or assets, in connection with bankruptcy proceedings, reorganization, or other change of control events.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Please note that we do not alter our Site's data collection and use practices when we see a Do Not Track signal from your browser.

European Privacy Rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to the United States.

California Privacy Rights

If you are a California resident you may request a notice from us describing what categories of personal information (if any) we have shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. You may request such notice once a year and free of charge. To request a notice, please contact us as provided in the "Contact Us" section and indicate in the email subject line "California Shine the Light Request." Please include your mailing address, state of residence and email address with your request.

In addition, if you are a California resident under the age of 18 and are a registered user of the Service, you may request that we remove content or information about you that you posted on the Service by (i) submitting a request in writing to privacy@earnm.com and (ii) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.

As of January 1, 2020, California residents also have the following rights under the California Consumer Privacy Act of 2018 (CCPA):

1. Right to Know About Personal Information Collected. California residents have the right to request that a business disclose to them the Personal Information it collects, uses, discloses, and sells, subject to certain exceptions and limitations.
2. Right to Request Deletion of Personal Information. California residents also have the right to request the deletion of their Personal Information collected or maintained by us, subject to certain exceptions and limitations.
3. Right to Opt-Out of the Sale of Personal Information. California residents have the right to opt-out of the sale of their Personal Information.
4. Authorized Agent. California residents may use an authorized agent to exercise certain privacy-related requests and rights on their behalf. Requests by mail shall include a power of attorney or a notarized statement properly signed by you. The mailing address is: The EARN'M Foundation, 94 Solaris Avenue, Camana Bay, PO Box 1348, Grand Cayman KY1-1108, Cayman Islands (Attn: California Privacy Requests).
5. Notice of Financial Incentive. California residents have the right to receive notice of financial incentives provided to them by a business.
6. Right to Non-Discrimination. California residents have a right not to receive discriminatory treatment by a business in the event that they exercise one or more of their privacy rights conferred by the CCPA.
7. How to Submit Your Request. You may submit requests by (i) emailing privacy@earnm.com (Attn: California Privacy Requests); or (ii) mailing your request to: The EARN'M Foundation, 94 Solaris Avenue, Camana Bay, PO Box 1348, Grand Cayman KY1-1108, Cayman Islands (Attn: California Privacy Requests).
8. Publication of CCPA Statistical Data. Starting January 1, 2021, and updated each year thereafter (if and as required by the CCPA), we will publish a summary of statistical data pertaining to California-resident consumer privacy requests.

The Site is not intended for individuals under the age of 18.

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at legal@earnm.com.